Aerospace & Defense Compliance Bullet (April 2017)
Welcome to the first issue of Baker McKenzie's Aerospace & Defense Compliance Bullet. The newsletter will highlight significant compliance developments relevant to companies in the Aerospace & Defense (A&D) industry and offer practical guidance with respect to business operations in various regions. We hope you find the content useful, and we welcome your feedback.
In this issue, we provide an update on what we know so far about the Trump administration's approach to enforcing the US Foreign Corrupt Practices Act (FCPA), and the implications for companies in the A&D industry. The FCPA is enforced criminally by the US Department of Justice (DOJ), and civilly by the US Securities and Exchange Commission (SEC). To date, neither the DOJ nor the SEC has initiated or resolved an FCPA enforcement action against a company since inauguration day on January 20, 2017. In the absence of enforcement actions, we are left to interpret the public statements by the enforcement authorities. So far these statements suggest that FCPA enforcement will continue in some fashion, but the exact details of the Trump administration's approach remain unknown. The two primary public statements available for interpretation are the DOJ's announcement of its intent to extend the DOJ FCPA Pilot Program, and the DOJ's publication of its Compliance Program Evaluation Guidance.
In this issue: